Section 148 notice- AO not considered objections & treated it under section 148A(b) – HC remands matter back to AO

Sahil Infra Creative Pvt Ltd Vs ITO (Gujarat High Court)

The position which unfolds in this case is that the petitioner assesse had filed its objections to the notice for reassessment under section 148 unamended issued to him, however, the Assessing Officer never attended to the objections dated 12.10.2022 and left it undecided. Thereafter, the old notice dated 30.6.2021 was treated under the new provisions to be the notice under section 148A(b) at this stage the petitioner was deprived of opportunity to put forth his case against the proposed reopening

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